Analysis - The Institute for Southern Studies

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Exhibit 5C-18 below shows the projected future annual CCR generation and three trends in beneficial use (i.e., scenario #1 increase without stigma, scenario #2 decrease with stigma, and scenario #3 no change in relation to the increasing baseline trend). Scenario #1 assumes that the increased cost of disposal from regulation will induce the electric utility industry to seek out additional CCR beneficial use markets thereby increasing future annual beneficial use of CCR above the increasing baseline trend. Experiences with the EPA RCRA Subtitle C hazardous waste program indicate that industry often increases annual recycling and materials recovery rates after RCRA regulation (e.g., after EPA has listed certain types and sources of secondary industrial materials as RCRA “hazardous wastes”). Thus, EPA regards the increased beneficial use Scenario #1 as the most likely outcome. A second curve in the Exhibit below displays the Scenario #2 decreased CCR beneficial use stigma effect under the Subtitle C regulatory option (this RIA does not apply scenario #2 under the Subtitle D options). The Exhibit also presents Scenario #3 in which future annual CCR beneficial use is projected to continue on its recent upwardly increasing trendline without any induced future change as a result of the CCR rule. The future annual beneficial use tonnages for both scenario #1 and scenario #2 are estimated in this RIA incrementally relative to the scenario #3 baseline trend. 182
Exhibit 5C-18 Beneficial Use Trends 180,000,000 165,000,000 150,000,000 135,000,000 120,000,000 CCRs (Short Tons) 105,000,000 90,000,000 75,000,000 60,000,000 45,000,000 30,000,000 15,000,000 0 2012 2017 2022 2027 2032 2037 2042 2047 2052 2057 Year CCRs Generated Baseline BU Subtitle C BU Subtitle C w/Stigma 183
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Regulatory Impact Analysis For EPA
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Table of Contents Executive Summary
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Executive Summary This RIA evaluate
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impoundments, the relative number t
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Summary Exhibit 3 Induced Effect of
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Summary Exhibit 6 Comparison of Reg
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Chapter 1 Problem Statement: The Ne
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Bevill Amendments 10 which exempted
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Just three weeks after the TVA’s
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2. Waste & Environmental Management
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This RIA did not discover similar d
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Exhibit 2A Identity of Other Indust
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Require review of surface impoundme
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Chapter 3 Baseline CCR Management i
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Exhibit 3C below, these 495 coal-fi
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Exhibit 3C State-by-State Electric
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3B. Types of CCR Disposal Units Es
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92 plants Offsite landfill fly ash
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electric utility plants in the data
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Exhibit 3E Annual CCR Disposition f
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3D. Size of CCR Disposal Units The
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costs for each type of disposal (no
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annual sampling for surface impound
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o Of the 25 state regulations revie
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Exhibit 3I Baseline Compliance with
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Baseline CCR Disposal Cost Estimati
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Before-tax costs: 50-year period:
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Baseline “Engineering Control”
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assume that the same water trucks w
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memorandum to George Garland, EPA,
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Exhibit 3K Summary of Industry & St
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($80,000 per year average Subtitle
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Validity Check of Baseline Cost Est
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Chapter 4 Estimated Cost for RCRA R
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B. Ancillary costs for CCR disposal
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location restriction mitigation inv
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o Impoundment berms: The average su
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State government average cost per w
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corrective action remedies usually
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Exhibit 4A Two Case Studies: Possib
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Biennial Report”). According to E
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4B.3 Land Disposal Restriction Cost
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The TVA cost study did not estimate
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Using the EPA ORCR 2009$ updated un
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Exhibit 4D Comparison of Annual O&M
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Exhibit 4E Summary of Wet Conversio
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o Recent Trend in CCR Impoundment P
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from coal to other fuels such as na
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o Result of Dry Conversion Cost Upd
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As summarized below in comparison t
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17% phase-out trend suggest the fut
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RIA 50- ye ar period Actual company
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4C. State-by-State Distribution of
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4D. Cost Estimation Uncertainty Thi
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Exhibit 4N Cost Estimation Uncertai
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In contrast to the Exhibit 5A list
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Step 2. Determine Potentially Affec
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Step 3. Apply EPA-ORCR 2009 Arsenic
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RISKn WELLREACH iRISK EDn N Where
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The constant slope allowed estimati
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Step 6. Monetize Future Avoided Can
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controls like surface-impoundment p
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Finally, for Subtitle C, there woul
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Exhibit 5A-12 Percentile of Cleanup
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Exhibit 5A-16 Per-Site Groundwater
Page 131 and 132: Multiple CCR disposal units at a si
Page 133 and 134: 5B. Benefit of Preventing Future CC
Page 135 and 136: As displayed below in Exhibit 5B-2,
Page 137 and 138: Where: = Observed arrival rate (0.
Page 139 and 140: Step 3. Calculate Future Impoundmen
Page 141 and 142: some surface impoundment regulation
Page 143 and 144: Exhibit 5B-8 Poisson Distribution (
Page 145 and 146: With these new distributions, EPA p
Page 147 and 148: Exhibit 5B-12 Scenario #2: Cleanup
Page 149 and 150: 5C. Induced Effect of RCRA Regulati
Page 151 and 152: Exhibit 5C-1 Estimate of Annual Mat
Page 153 and 154: Exhibit 5C-3 below presents a 2004
Page 155 and 156: To avoid double-counting of economi
Page 157 and 158: 5C2. Potential Effect of RCRA Regul
Page 159 and 160: Others take a different view on how
Page 161 and 162: Exhibit 5C-7 EPA Extrapolation of E
Page 163 and 164: Based on the most recent CCR benefi
Page 165 and 166: Beneficial uses of CCR have been co
Page 167 and 168: Exhibit 5C-12 Beneficial Use Trend
Page 169 and 170: Increases due to increased disposal
Page 171 and 172: “Using [coal] fly ash in building
Page 173 and 174: Exhibit 5C-14 Historical Annual Per
Page 175 and 176: Hypothetical expansion of CCR custo
Page 177 and 178: Step 6: Apply Estimated Induced Eff
Page 179 and 180: Exhibit 5C-16 Scenario #1: Increase
Page 181: Exhibit 5C-17 Scenario #2: Decrease
Page 185 and 186: Exhibit 5C-19 Scenario #1: Benefit
Page 187 and 188: Exhibit 5C-21 Scenario #2: Cost of
Page 189 and 190: Step 10: Quantify Potential Capacit
Page 191 and 192: Chapter 6 Comparison of Regulatory
Page 193 and 194: Exhibit 6B Comparison of Regulatory
Page 195 and 196: Exhibit 6D Comparison of Regulatory
Page 197 and 198: Exhibit 6F Comparison of Regulatory
Page 199 and 200: Exhibit 6F Scaling Factors (Extrapo
Page 201 and 202: Exhibit 6G Estimate of Subtitle D (
Page 203 and 204: detect contamination early and thus
Page 205 and 206: Step 1: Downloaded the annual milli
Page 207 and 208: Exhibit 7A State by State Breakout
Page 209 and 210: Small government: Based on the RFA/
Page 211 and 212: Step 3 & Step 4: Determine and docu
Page 213 and 214: Factor #2 of 2: The small business
Page 215 and 216: how much they use or indeed how muc
Page 217 and 218: Collection of Minority & Low-Income
Page 219 and 220: Comparison of Minority & Low-Income
Page 221 and 222: Exhibit 7G Minority and Low-Income
Page 223 and 224: Exhibit 7H Comparison of Minority a
Page 225 and 226: o The state-by-state range of minor
Page 227 and 228: CCR fraction #3: CCR fraction #4:
Page 229 and 230: 7D. Child Population Statistics (Ex
Page 231 and 232: Comparison of Child Populations Liv
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Count of plant unique ZCTAds Exhibi
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Exhibit 7K Comparison of Child Popu
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7E. Unfunded Mandates (UMRA) & Fede
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Findings for UMRA Impact and Federa
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Exhibit 7M List of 74 Coal-Fired El
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Analysis - The Institute for Southern Studies

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